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    <title>Partial taxpayer relief: electrical fittings depreciated at 10%; foreign-exchange loss allocation deleted; s.40(a)(ia) TDS not disallowable; s.10B set-off reversed &amp;D</title>
    <link>https://www.taxtmi.com/highlights?id=92033</link>
    <description>ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as &quot;furniture and fittings.&quot; Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)&#039;s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)&#039;s curative-construction is affirmed. Apportionment of R&amp;D expenses to EOUs is deleted, where the assessee had booked R&amp;D costs to those units. AO&#039;s pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)&#039;s treatment is upheld.</description>
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    <pubDate>Fri, 29 Aug 2025 08:56:29 +0530</pubDate>
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      <title>Partial taxpayer relief: electrical fittings depreciated at 10%; foreign-exchange loss allocation deleted; s.40(a)(ia) TDS not disallowable; s.10B set-off reversed &amp;D</title>
      <link>https://www.taxtmi.com/highlights?id=92033</link>
      <description>ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as &quot;furniture and fittings.&quot; Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)&#039;s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)&#039;s curative-construction is affirmed. Apportionment of R&amp;D expenses to EOUs is deleted, where the assessee had booked R&amp;D costs to those units. AO&#039;s pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)&#039;s treatment is upheld.</description>
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      <pubDate>Fri, 29 Aug 2025 08:56:29 +0530</pubDate>
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